MODEL WEALTH

Model Wealth, Inc. Client Relationship Summary (Form CRS) May 2026 Model Wealth, Inc. is registered with the U.S. Securities and Exchange Commission as an investment adviser. Brokerage and investment advisory services and fees differ, and it is important that you understand those differences. Free and simple tools are available to you to research firms and financial professionals at Investor.gov, which also provides educational materials about broker-dealers, investment advisers, and investing. What investment services and advice can you provide me? We provide investment advisory services, including: o Wealth Management (Comprehensive Service): Ongoing financial planning and portfolio management. We continuously monitor your investments and typically have discretionary authority, meaning we can buy and sell investments in your account without asking you in advance. You may place reasonable restrictions on this authority. o Financial Planning (Standalone Service): One-time or project-based financial planning. We do not monitor investments or place trades under this arrangement. We do not impose formal account minimums; however, certain services may not be appropriate depending on your financial situation and the scope of services required. For additional details, please see our Form ADV, Part 2A (Brochure), available upon request or at the SEC Investment Adviser Public Disclosure website (www.adviserinfo.sec.gov) using CRD# 299798. Ask us: o Given my financial situation, should I choose an investment advisory service? Why or why not? o How will you choose investments to recommend to me? o What is your relevant experience, including licenses, education, and other qualifications? What do those qualifications mean? What fees will I pay? For our Wealth Management services, we charge either: o A flat annual fee, based on the complexity of your financial situation and scope of services, or o A percentage of assets under management (AUM), billed quarterly in advance For standalone financial planning, we charge either: o A fixed fee, or o An hourly fee, due upon completion of services In addition to our fees, you will incur other costs such as: o Custodian fees o Brokerage commissions o Mutual fund and ETF expense ratios o Retirement account fees and other transaction-related costs Model Wealth does not receive any of these additional fees. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make over time. Please make sure you understand what fees and costs you are paying. Ask us: o Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?  Model Wealth, Inc. Client Relationship Summary (Form CRS) May 2026 What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have? When we act as your investment adviser, we are held to a fiduciary standard, meaning we must act in your best interest and not place our interests ahead of yours. At the same time, the way we are compensated creates certain conflicts of interest: • If we charge a percentage of assets under management, we have an incentive to encourage you to increase assets in your accounts. If we charge a flat fee, we have an incentive to manage our time efficiently and limit the scope of services provided. • • We also have an incentive to recommend ongoing services, as we are compensated through advisory fees. In certain cases, we may have limited authority, at your direction, to move money between your accounts or to third parties you designate. We cannot change payees or move money for our own benefit, and your custodian provides confirmations directly to you. We work to mitigate these conflicts through our fiduciary duty and by providing advice that we believe is in your best interest. For more information, please see our Form ADV, Part 2A, available at www.adviserinfo.sec.gov using CRD# 299798. Ask us: o How might your conflicts of interest affect me, and how will you address them? How do your financial professionals make money? Our firm is compensated solely through advisory fees paid by clients. Our financial professionals are compensated through: o Salaries o Bonuses o Profit distributions (for owners of the firm) They are not compensated based on: o The amount of client assets serviced o The sale of specific investment products o Commissions or transaction-based compensation Do you or your financial professionals have legal or disciplinary history? No. Visit Investor.gov for a free and simple search tool to research our firm and financial professionals. Ask us: o As a financial professional, do you have any disciplinary history? For what type of conduct? Where can I find additional information? For additional information about our services, or to request a copy of this Client Relationship Summary or our Form ADV, Part 2A, please contact: Alex Offerman Phone: (630) 381-1170 Email: alex.offerman@modelwealth.com Ask us: o Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? o o Who can I talk to if I have concerns about how this person is treating me? 

Item 1 – Cover Page MODEL WEALTH, INC. Form ADV Part 2A FIRM BROCHURE Mailing Address: 1755 S. Naperville Road, Suite 100 Wheaton, IL 60189 (630) 381-1170 www.modelwealth.com March 31, 2026 This brochure provides information about the qualifications and business practices of Model Wealth, Inc. If you have any questions about this brochure, please contact us at (630) 381-1170 or letschat@modelwealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Model Wealth, Inc. is a registered investment advisor. Registration of an Investment Advisor does not imply any level of skill or training. Additional Information about Model Wealth, Inc. is available on the SEC’s website at www.advisorinfo.sec.gov.  Item 2 – Material Changes Model Wealth, Inc. (“Model Wealth”, the “Firm”, “we”, or “us”) is required to file with the United States Securities and Exchange Commission an updated version of ADV within 90 days of the end of the Firm’s fiscal year. We will ensure that you will receive updated Brochures with a summary of materials changes within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. Annual Update Model Wealth is required to advise you of any material changes to the Firm Brochure (ADV 2A) from our last annual update. Since our last amendment filing on 05/20/2025, we have the following material changes to disclose:  Item 5: “Fees and Compensation” has been amended to disclose an increase in the Firm’s hourly rate to $400 per hour. Previous Amendments: Amendment – 5/20/2025  Item 4: We’ve updated our address, as Model Wealth no longer has a physical office. Our new mailing address is: 1755 S. Naperville Road, Suite 100, Wheaton, IL 60189. Annual Amendment – 3/31/2025     Item 4: “Advisory Business” has been amended to disclose the addition of Separately Managed Accounts / Turnkey Asset Management Programs with Vanguard Personalized Investment Management, LLC. (“VPIM”) and continuing our relationship with Betterment for Advisors, LLC. Item 5: “Fees and Compensation” has been amended to disclose a change in Wealth Management Fees to $1,000 to $50,000 (from previously $6,000 to $50,000). Item 5: “Fees and Compensation” has been amended to remove percentage based advisory fees being assessed at Betterment from Donovan Sanchez’s (formerly of Skyview Wealth Management) clients. This is to better align with Model Wealth’s flat fee wealth management services. Item 5: “Fees and Compensation” has also been amended to disclose fees charged by Vanguard Personalized Investment Management, LLC. (“VPIM”) and Betterment for Advisors, LLC. Amendment – 10/01/2024  Updated address to reflect our new mailing address. Our previous physical / mailing address was 55 S. Main St., Suite 380, Naperville, IL 60540 and our new mailing address only is 50 S. Main St., Suite 200, Naperville, IL 60540. At any time, you may view the current Brochure on-line at the SEC’s Investment Adviser Public Disclosure website (www.adviserinfo.sec.gov). You may also request a copy of this Brochure at any time by contacting us at (630) 381-1170 or letschat@modelwealth.com.  Item 3 – Table of Contents Item 1 – Cover Page .................................................................................................................................. 1 Item 2 – Material Changes ........................................................................................................................ 2 Item 3 – Table of Contents ........................................................................................................................ 3 Item 4: Advisory Business ........................................................................................................................ 4 Item 5: Fees and Compensation ................................................................................................................ 7 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................... 9 Item 7: Types of Clients ............................................................................................................................ 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 9 Item 9: Disciplinary Information ............................................................................................................ 11 Item 10: Other Financial Industry Activities and Affiliations ................................................................ 11 Item 11: Code of Ethics, Participation, or Interest in Client Transactions and Personal ................ 11 Trading .................................................................................................................................................... 11 Item 12 - Brokerage Practices ................................................................................................................. 12 Item 13 - Review of Accounts ................................................................................................................ 13 Item 14 - Client Referrals and Other Compensation ............................................................................... 14 Item 15 - Custody .................................................................................................................................... 14 Item 16 - Investment Discretion .............................................................................................................. 15 Item 17 - Voting Clients Securities ......................................................................................................... 15 Item 18 - Financial Information .............................................................................................................. 15  Item 4: Advisory Business Model Wealth, Inc. was incorporated in the State of Illinois in May 2012. Randall T. Bruns, President, and Alex C. Offerman, Chief Compliance Officer, are the principals of the Firm. Model Wealth is a fully virtual, fee-only financial planning and wealth management firm that provides investment advisory services to individuals, families, estates, and trusts. The Firm offers services under two primary arrangements: (1) Financial Planning Engagements, which may be billed on an hourly or fixed (project-based) basis, and (2) Wealth Management services, which include ongoing financial planning and investment management for a flat annual fee. Financial Planning Engagements (Hourly or Project-Based) Under a Financial Planning Engagement, clients engage Model Wealth to address specific financial goals or to develop a comprehensive financial plan. These services are provided on either an hourly or fixed (project-based) fee basis. Depending on the client’s needs, Model Wealth may address one or more of the following areas: o Asset Allocation o Cash Flow Planning and Management o Education Funding o Estate Planning and Asset Titling o Investment Portfolio Review o Investment Management o Risk Management (Property and Casualty) o Retirement Planning o Social Security o Stock Option/Restricted Stock Planning o Tax Planning At the outset of each engagement, Model Wealth conducts an initial review of the client’s financial situation to determine whether its services are appropriate and, if so, the scope of services to be provided. Financial Planning Engagements are limited in scope and do not include ongoing monitoring or continuous investment management unless the client enters into a separate Wealth Management agreement. Model Wealth’s compensation under this arrangement is limited to the agreed-upon fee for services, and the Firm does not receive any additional compensation related to the recommendations provided. Wealth Management Relationships Model Wealth offers an ongoing Wealth Management program that integrates portfolio management and comprehensive financial planning under a simplified, flat annual fee arrangement. This program is designed for individuals and families who require continuous oversight of both their investment portfolio and broader financial life, particularly in situations where periodic or hourly advice and more limited investment solutions would be insufficient. Wealth Management Relationships typically commence following the completion of an initial financial planning engagement. This process allows both the client and Model Wealth to determine  whether an ongoing advisory relationship is appropriate given the client’s needs and complexity. Wealth Management Relationships generally include, but are not limited to, the following services: o Regularly scheduled reviews addressing all aspects of the client’s financial situation o Ongoing portfolio management and oversight across client accounts o Portfolio rebalancing and tax-aware investment management o Access to a secure client portal providing consolidated reporting of assets, liabilities, cash flows, and performance o Access to financial planning tools to organize and monitor the client’s financial life o Coordination and collaboration with third-party professionals, including accountants, attorneys, insurance professionals, and other advisors, as appropriate All client assets are held at an independent qualified custodian. Model Wealth constructs and manages client portfolios based on each client’s stated investment objectives, financial goals, and risk tolerance. Clients may impose reasonable restrictions on the management of their accounts, including instructing Model Wealth not to purchase certain securities or types of securities. Any such restrictions must be provided to Model Wealth in writing and accepted by the firm. Discretionary and Non-Discretionary Wealth Management For the ongoing management of a client’s account, the client will authorize Model Wealth with discretionary or non-discretionary investment management authority. Most clients authorize Model Wealth with discretionary investment management authority. This means that Model Wealth will have the authority to place trades in a client’s account without prior consent by the client. However, certain clients may have restrictions from their employers or involvement with publicly traded companies, requiring trades to be approved before they are submitted, meaning that their accounts will be managed on a non-discretionary basis. Wrap Fee Programs Model Wealth does not participate in any wrap fee investment management programs. ADV Client Delivery If a client does not receive an ADV Part 2 at least 48 hours prior to entering into an advisory agreement, the client has a right to terminate the contract without penalty within five business days after entering into the contract. Otherwise, the client or Model Wealth may terminate the agreement with written notice to the other party at least fourteen (14) calendar days in advance. Assets Under Management As of December 31, 2025, Model Wealth managed approximately $318,160,000 of client assets. This includes approximately $314,470,000 of discretionary assets and $3,690,000 of non- discretionary assets. Separately Managed Accounts (“SMA”) and Turnkey Asset Management Programs (“TAMP”) Model Wealth may allocate (and/or recommend that the client allocate a portion of a client’s investment assets among unaffiliated separately managed accounts (“SMAs”) and/or independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the SMA or independent investment managers shall have day-to-day responsibility for  the active discretionary management of the allocated assets, including, to the extent applicable, proxy voting responsibility. Model Wealth shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Model Wealth shall consider in recommending SMAs or independent investment managers include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, fees, and research. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, Model Wealth’s investment advisory fee as set forth in Item 5 below and which will be disclosed to the client before entering into the Independent Manager engagement and/or subject to the terms and conditions of a separate agreement between the client and the Independent Manager(s). Alex Offerman and Randall Bruns remains available to address any questions that a client or prospective client may have regarding the allocation of account assets to an Independent Manager(s), including the specific additional fee to be charged by such Independent Manager(s). Wealth utilizes two independent third-party investment managers: Betterment for Advisors and Vanguard Personalized Indexing Management, LLC (“VPIM”) (collectively referred to as “Independent Managers”). Betterment for Advisors, a division of Betterment LLC (“Betterment”), is an online investment platform commonly referred to as a “robo-advisor.” Betterment provides automated, algorithm- driven portfolio management services, including asset allocation, rebalancing, and tax optimization. Vanguard Personalized Indexing Management, LLC (“VPIM”) provides direct indexing services, which involve constructing customized portfolios of individual securities designed to track the performance of a specified index while allowing for tax management and portfolio personalization. Model Wealth recommends these Independent Managers as part of its overall investment strategy and ongoing portfolio management services. In such cases, Model Wealth is responsible for conducting initial and ongoing due diligence on each Independent Manager, including an evaluation of their investment approach, performance, fees, operational capabilities, and overall suitability for client portfolios. Clients should be aware that the Independent Managers charge their own fees for investment management services, which are separate from and in addition to the advisory fees charged by Model Wealth. These fees are disclosed in the respective Independent Manager’s Form ADV Part 2A and related client agreements. As a result, clients will incur a higher overall cost than if the services of only one investment manager were utilized. Model Wealth does not receive any direct compensation from Betterment or VPIM for recommending or selecting these Independent Managers. However, Model Wealth has an incentive to recommend these managers as they are integrated into the firm’s service model and operational processes, which may create a conflict of interest. Model Wealth seeks to mitigate this conflict by recommending Independent Managers that it reasonably believes are in the best interest of its clients. Clients are not obligated to use the Independent Managers recommended by Model Wealth and  may direct the firm to implement investment strategies using other platforms or managers, subject to Model Wealth’s ability to effectively manage the portfolio under such circumstances. Item 5: Fees and Compensation The specific fees charged by Model Wealth are established in a client’s written agreement with Model Wealth and depend upon the nature of the engagement and the services rendered. Fees are negotiable at Model Wealth’s sole discretion. Financial Planning Fees Clients engage Model Wealth initially to provide services on specific tasks or to evaluate their financial situation and provide a comprehensive financial plan without an ongoing relationship. Under those circumstances, Model Wealth will either bill specifically by the hour or will quote a fixed fee based upon an estimate of the amount of time involved to provide that service. Model Wealth’s current hourly rate is $400, which may change from time to time. Hourly based fees are due upon completion of the work involved. At the outset of project-based engagements, one half of the agreed upon fee is due. The remainder of the fee is payable on the delivery of the plan or completion of the service. Clients can terminate the agreement, and Model Wealth will be refunded on a prorated basis based on services performed through the date of termination. Following the delivery of the plan or the completion of the service, clients can seek out clarification from Model Wealth for a period of 30 days without incurring a charge; thereafter, clients can, from time to time, seek out the guidance and advice of Model Wealth regarding revisions and implementation at the then current hourly rate. Clients can pay these fees via check or credit card. Wealth Management Fee Model Wealth provides ongoing financial planning and investment management services for a flat annual fee. This fee is based on the scope of services to be provided and the complexity of the client’s overall financial situation. Annual fees may range up to $50,000 for highly complex client engagements. However, most clients pay between $7,900 and $12,000 per year. Fees are generally billed quarterly, either in advance or in arrears, depending on the client’s specific custodian and/or investment manager. The specific fee arrangement, billing methodology, and payment terms are outlined in the wealth management agreement executed between the client and Model Wealth prior to the commencement of services. In certain circumstances, Model Wealth may agree to charge a percentage-based fee not to exceed 0.75% of the client’s total portfolio value, particularly where a flat annual fee would be excessive relative to the size of the portfolio. Under such arrangements, the total advisory fee will not exceed the amount that would otherwise be charged under a comparable flat fee structure. Model Wealth’s fees are negotiable at the firm’s discretion based on factors including, but not limited to, the complexity of the client’s financial situation, the level and scope of services to be provided, and the anticipated time and resources required to service the relationship. Clients may terminate their advisory agreement at any time, upon written notice, in accordance with the terms of the agreement. Upon termination, any unearned fees paid in advance will be  refunded on a pro rata basis, and any earned but unpaid fees will be due and payable through the date of termination. Pre-existing advisory clients are charged fees in accordance with the terms in effect at the time they entered into the advisory relationship. As a result, similarly situated clients may pay different fees. Betterment for Advisors Betterment for Advisors Fees will be deducted directly from accounts held by the custodian. Betterment for Advisors Fees are payable quarterly, in arrears, for the previous calendar quarter. The fee is currently 0.15% but is subject to a maximum annual fee of 0.50%. This fee is in addition to the Model Wealth’s management fee. Additional information relating to the Betterment for Advisors Fee may be obtained in their Disclosure Brochure. Vanguard Personalized Investment Management (“VPIM”) Vanguard Personalized Investment Management Fees will be deducted directly from accounts held by the qualified custodian (Charles Schwab). VPIM fees are payable quarterly, in advance, for the upcoming calendar quarter based upon the previous quarter-end average balance. The fee is currently tiered and has a maximum annual fee of 0.20%. This fee is in addition to the Model Wealth’s management fee. Additional information relating to the VPIM Fee may be obtained in their Disclosure Brochure. Fee Billing Clients may pay Model Wealth’s annual Wealth Management fee either directly (e.g., by check or electronic payment) or by authorizing the Firm to deduct fees from their account(s) held at an independent qualified custodian. Any such authorization will be provided in writing by the client. Model Wealth may adjust its fees from time to time based on changes in the client’s financial situation, scope of services, or overall complexity. Any increase in fees will be communicated to the client in advance and will not become effective without the client’s consent. Clients may terminate the advisory relationship at any time in accordance with the terms of the agreement. Fees are generally billed quarterly, in advance. Accounts opened or terminated during a billing period will be charged a prorated fee based on the number of days services are provided during the period. Upon termination, any prepaid and unearned fees will be refunded on a prorated basis. Other Fees and Expenses Clients may incur certain fees and expenses imposed by third parties in connection with the maintenance of their accounts. These may include custodial fees, account maintenance fees, transaction charges, and fees associated with retirement accounts (e.g., IRA fees), as well as banking-related charges. Clients may also incur fees and expenses associated with investments, such as mutual funds or exchange-traded funds. These fees are described in the applicable fund prospectus and may include management fees and other expenses. Model Wealth does not receive any portion of these fees.  Credit Card Payments Clients who elect to pay advisory fees by credit card may incur transaction or processing fees charged by their card issuer or payment processor. Model Wealth does not retain any portion of such fees. Item 6: Performance-Based Fees and Side-By-Side Management Model Wealth does not charge any performance-based fees or fees related to side-by-side management. Item 7: Types of Clients Model Wealth’s clients are primarily individuals, high net worth individuals, families, pension and profit-sharing plans, trusts, estates, charitable organizations, and small businesses. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Model Wealth believes that investments should be managed passively and implemented with cost- effectiveness and tax-efficiency in mind. Our investment strategy begins with a general long-term acceptance of the Efficient Market Hypothesis, which states that the primary driver of a portfolio’s risk and return characteristics is determined by asset allocation and not security selection. As countless studies have proven, active management underperforms the market. Model Wealth believes that selecting investments or investment managers that will outperform the market is more an act of luck than skill. To protect Model Wealth, Inc. clients from the higher costs of active management and the underperformance that can result, clients are advised to invest in passive strategies. The investment vehicles most commonly purchased for Model Wealth, Inc. clients are shares of registered, open-end mutual funds, exchange-traded funds, and individual equity and fixed income securities. Many of these investments can be purchased directly by clients without utilizing the services of an advisor. Mutual funds and exchange traded funds have embedded management fees and trading expenses. These fees and expenses are detailed in each fund’s prospectus. The following is a non-exclusive, non-static list of securities that Model Wealth, Inc. utilizes for its clients:  Equity Securities  Mutual Fund Securities  Exchange-traded funds  Corporate debt securities, commercial paper, and certificates of deposit  Municipal securities  U.S. Government Securities  Closed end funds  Direct Indexing Investing in securities involves a risk of loss that clients should be prepared to bear. Different types of investments carry varying degrees of risk, and an investor should not assume that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Model Wealth, Inc.) will be profitable or equal any specific performance levels. Without limitation, investors generally face the following risks:  Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk may be caused by external factors independent of the fund’s specific investments as well as due to the fund’s specific investments. Additionally, each security’s price will fluctuate based on market movement and emotion, which may, or may not, be due to the security’s operations or changes in its true value. For example, political, economic, and social conditions may trigger market events which are temporarily negative, or temporarily positive. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a decline in market value. Model Wealth, Inc. methods of analysis and investment strategies do not present any significant or unusual risks. However, every method of analysis has its own inherent risk. Direct Indexing Risk Considerations Model Wealth may utilize direct indexing strategies for certain clients. Direct indexing involves purchasing individual securities intended to replicate the performance of a specific market index, often combined with tax-loss harvesting strategies. While this approach may offer potential tax efficiencies and customization benefits, it also involves additional risks that clients should consider. Tracking Error Risk Direct indexing portfolios may not perfectly replicate the performance of the intended index due to factors such as transaction costs, tax-driven trading decisions, and the exclusion or underweighting of certain securities. As a result, client portfolios may experience performance that deviates from the benchmark index. Concentration Risk Particularly during the initial implementation phase or in smaller portfolios, direct indexing strategies may result in concentrated positions in a limited number of securities. This concentration may increase volatility and the potential for loss if one or more of those securities underperform.  Tax-Loss Harvesting Limitations: The ability to harvest tax losses may diminish over time as positions are reset to higher cost bases or as market conditions change. As a result, the tax benefits associated with direct indexing strategies may decrease over the life of the portfolio. Wash Sale Considerations: Tax-loss harvesting strategies must comply with wash sale rules under applicable tax law. Clients with multiple accounts, including those held outside of Model Wealth or across household members, may inadvertently trigger wash sales if substantially identical securities are purchased within the restricted time window. This may reduce or eliminate the intended tax benefits of the strategy. Clients should understand that direct indexing strategies involve trade-offs between tax optimization and portfolio tracking, and there is no guarantee that such strategies will achieve their intended tax or investment outcomes. Item 9: Disciplinary Information Neither Model Wealth nor any of its associated persons have ever been convicted of, pled guilty or no contest to any felony or misdemeanor in a criminal or civil action in any foreign or domestic court. Neither Model Wealth nor any of its associated persons have ever been part of a proceeding before the SEC or any other industry regulatory agency or self-regulatory organization. Item 10: Other Financial Industry Activities and Affiliations Model Wealth is registered as an investment adviser and provides advisory services in that capacity only. Model Wealth is not registered as a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor. Model Wealth does not have any material relationships or affiliations with any related persons engaged in the financial services industry, including broker-dealers, investment companies, other investment advisers, financial planning firms, commodity pool operators, commodity trading advisors, futures commission merchants, banks or thrift institutions, accounting firms, law firms, insurance companies or agencies, pension consultants, real estate brokers or dealers, or entities that create or sponsor limited partnerships. Item 11: Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading Code of Ethics Model Wealth strives to comply with applicable laws and regulations governing its practices; therefore, the Code of Ethics includes guidelines for professional standards of conduct for its Associated Persons. Model Wealth’s goal is to protect client’s interests at all times and to demonstrate a commitment to the fiduciary duties of honesty, good faith, and fair dealing with clients. All Associated Persons are expected to adhere strictly to these guidelines. Persons associated with Model Wealth are also required to report any violations of our Code of Ethics. Additionally, Model Wealth maintains and enforces written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about clients or client account holdings by persons associated with Model Wealth.  Model Wealth also abides by the Code of Ethics and Professional Responsibility adopted by the CFP Board of Standards, Inc. the principles of which include: Principle One – Act with honesty, integrity, competence, and diligence. Principle Two – Act in the client’s best interests. Principle Three – Exercise due care. Principle Four – Avoid or disclose and manage conflicts of interest. Principle Five – Maintain the confidentiality and protect the privacy of client information. Principle Six – Act in a manner that reflects positively on the financial planning profession. Clients or prospective clients may obtain a copy of our Code of Ethics by contacting Model Wealth at the telephone number on the cover page of this brochure. Participation or Interest in Client Transactions Model Wealth does not currently participate in securities in which it has a material financial interest. Model Wealth and its Associated Persons, as a matter of policy, do not recommend to clients, or buy or sell for client accounts, securities in which the firm or its Associated Persons has a material financial interest. Personal Trading Practices Model Wealth or its Associated Persons may buy or sell the same securities that they recommend to clients or securities in which clients are already invested. A conflict of interest may exist in such cases because Model Wealth Associated Persons have the ability to trade ahead of clients and potentially receive more favorable prices than they will receive. To eliminate this conflict of interest, it is Model Wealth’s policy that its Associated Persons shall not have priority over client accounts in the purchase or sale of securities. Item 12 - Brokerage Practices Model Wealth recommends the brokerage and custodial services of Charles Schwab & Co., Inc. (“Schwab”) and Betterment Securities (“Betterment”), each of which is a registered broker-dealer and a member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). Although clients may direct Model Wealth to use a broker-dealer of their choosing, Model Wealth generally recommends that clients establish brokerage accounts with Schwab or Betterment. Best Execution Model Wealth seeks to obtain best execution for client transactions, taking into account a range of factors beyond price. While commission rates and transaction costs are considered, they are not the sole determinants of best execution. Model Wealth also evaluates the overall quality of brokerage services, including execution capability, financial stability, technology, research, reputation, and responsiveness to clients and the Firm. In recognition of the value of brokerage services provided by Schwab and Betterment, clients may pay higher commissions and/or trading costs than those that may be available through other broker- dealers. Model Wealth has a fiduciary duty to seek best execution for client transactions. In fulfilling this  obligation, Model Wealth periodically reviews the execution quality and overall services provided by Schwab and Betterment. These reviews include consideration of execution capability, transaction costs, responsiveness, available technology, and the value of research and other services. Model Wealth also considers reasonably available alternatives and evaluates whether its current custodial relationships continue to provide best execution under prevailing circumstances. These reviews are conducted at least annually, or more frequently as needed, and are documented as part of the Firm’s compliance program. Research and Other Benefits As a registered investment adviser, Model Wealth has access to the institutional platforms of Schwab and Betterment. Through these platforms, Model Wealth may receive research products, technology, and other services that assist in investment decision-making and account management. These services may include financial publications, company and industry research, portfolio management tools, rebalancing software, and other related services. These products and services are generally provided to investment advisers that utilize the custodians’ institutional platforms and are not considered to be paid for with soft dollars. However, clients should be aware that brokerage commissions or transaction costs charged by a custodian may be higher than those charged by other broker-dealers that do not provide such services. Aggregation of Orders / Block Trading Model Wealth generally does not aggregate (or “block”) client transactions for the purchase or sale of securities. As a result, clients may receive different prices for the same securities transactions than other clients and may not be able to buy or sell the same quantities of securities at the same time. In addition, clients may incur higher commissions, fees, and/or transaction costs than those that could be achieved through aggregated transactions. Item 13 - Review of Accounts For clients who engage Model Wealth for ongoing, comprehensive services, Model Wealth monitors client accounts on an ongoing basis. Clients are responsible for notifying Model Wealth promptly of any changes to their investment objectives, risk tolerance, or financial circumstances. Model Wealth conducts portfolio reviews at least semi-annually. These reviews may be performed by any of the Firm’s investment adviser representatives and include an evaluation of portfolio holdings, changes in account value, and the allocation of assets relative to the client’s investment objectives and recommended strategy. Additional reviews may be conducted upon the occurrence of significant events, including changes in a client’s financial situation or investment objectives, material market events, or upon client request. Clients receive written transaction confirmations and account statements directly from their broker- dealer or custodian at least quarterly. Model Wealth may also provide periodic reports and/or access to an online client portal that includes account information, holdings, and performance data. Any performance information provided by Model Wealth is for informational purposes only and may vary from custodial statements due to differences in valuation methodologies, timing, or account aggregation. Clients should rely on custodial statements as the official record of their accounts and should carefully review such statements for accuracy.  Item 14 - Client Referrals and Other Compensation Model Wealth, Inc. does not receive any economic benefit, directly or indirectly, from third parties for client referrals and does not provide compensation to third parties for referring clients to the Firm. Item 15 - Custody Model Wealth, Inc. does not take physical custody of clients’ assets or provide custodial services. However, because the Client’s independent custodian may directly debit their account(s) for the payment of advisory fees, Model Wealth is deemed to have constructive custody over client funds or securities. Client funds and securities are held by a bank, broker-dealer, or other independent, qualified custodian. Clients will receive account statements from the independent, qualified custodian(s) holding their funds and securities at least quarterly. The account statements from custodian(s) will indicate the amount of Model Wealth’s advisory fees deducted from their account(s) each billing period. Clients should carefully review account statements for accuracy. Model Wealth reports may vary from custodial statements based on account procedures, reporting dates, valuation methodologies, or certain securities. Model Wealth also aids with asset movements to simplify the management of clients’ complex financial situations. As such, clients may authorize Model Wealth through Standing Letters of Authorization (“SLOAs”) to move funds between client accounts or to third parties previously designated by the client, without obtaining written client consent for each movement of funds. Because of the authority granted to Model Wealth under these SLOAs, the Firm is deemed to have constructive custody over client funds or securities. In utilizing SLOAs, Model Wealth adheres to safeguards consistent with SEC guidance to avoid the surprise examination otherwise required under the Custody Rule. Specifically: o The client provides written authorization to the qualified custodian, specifying the accounts and/or third parties to which transfers may be made; o The client retains ownership and control of the destination account(s), and such accounts are held in the client’s name or in the name of a third party previously designated by the client; o Model Wealth does not have the authority to designate itself or any of its supervised persons as a payee or recipient of client funds; o Model Wealth does not have the authority to change or modify third-party information, including account numbers or recipient details, without client authorization; o The qualified custodian performs appropriate verification of the client’s instructions and provides confirmations of each transfer directly to the client; o The client may terminate or modify the SLOA at any time by providing written notice to the qualified custodian.  These procedures are designed to ensure that Model Wealth’s authority is limited to client-directed transfers and that appropriate safeguards are in place consistent with applicable regulatory guidance. Item 16 - Investment Discretion Model Wealth is typically granted discretionary authority to manage client accounts. When granted, this authority allows Model Wealth to determine, without obtaining prior client consent for each transaction, the securities to be purchased or sold and the amount of such securities, consistent with the client’s investment objectives. Clients may impose reasonable restrictions on this discretionary authority, provided such restrictions are communicated to Model Wealth in writing and accepted by the Firm. For accounts in which discretionary authority has not been granted, Model Wealth will obtain client consent prior to the execution of each transaction. Item 17 - Voting Clients Securities Model Wealth does not have authority to vote proxies on behalf of clients and does not do so. Clients retain the responsibility for receiving and voting proxies for securities held in their accounts. Clients will receive proxy materials directly from the account custodian(s) or transfer agents. Upon request, Model Wealth may provide clients with advice regarding proxy voting matters. In providing such advice, Model Wealth will disclose any material conflicts of interest to the client. Item 18 - Financial Information Registered investment advisers are required under this Item to disclose certain financial information regarding their financial condition. Model Wealth has no financial condition that would impair its ability to meet its contractual or fiduciary obligations to clients, has not been subject to any bankruptcy proceedings, and does not require prepayment of fees exceeding $1,200 more than six months in advance. Accordingly, Model Wealth is not required to provide a balance sheet or additional financial disclosures under this Item.